September 25, 2014 advance copy via email
The Honorable Dow Constantine The Honorable Kathy Lambert, District 3
King County Executive King County Councilmember
King County Chinook Building King County Courthouse
401 Fifth Avenue, Suite 800 516 Third Avenue, 12th Floor
Seattle, WA 98104 Seattle, Washington 98104
Subject: Opposition to Proposed Gunshy Manor Development along the Red Brick Road
Sustainable Redmond is a grassroots organization with the mission of being a catalyst for moving Redmond’s
citizens, businesses, and local government toward sustainability. Therefore, we advocate transparency in City and
County development processes, better public notice of development proposals and full community engagement
We wish to bring your attention to a proposed development (Gunshy Manor) on the Red Brick Road, which is a
historical landmark in King County. The Red Brick Road (located on 196th Ave NE between SR 202 and NE Union Hill
Road) is adjacent to the boundary of the City of Redmond and is an important historic and agricultural valley that
preserves more than a mile of paved road from the original Yellowstone Trail, dating from 1913. The road runs
through more than 100 acres of intact wetlands, some privately owned and some preserved as the Evans Creek
Natural Area. It has come to our attention that King County is in the process of receiving pre-applications for a new
development project along the road that will build 25 additional homes on property immediately adjacent to Evans
Creek Natural Area.
There are a range of direct, indirect and cumulative environmental impacts which should be addressed in the
Evasion of County Wetland Protection Regulations: The owners of the subject property have been actively filling
and channelizing a part of the Evans Creek wetland and building impervious surface roads in the wetland buffer for
a number of years, without any permits and without a Farm Management Plan. This activity appears to be an
attempt to evade environmental laws by providing County regulators with a fait accompli: land whose hydrological
connection to the (now degraded) wetland has been severed, thus justifying proposals to reduce the wetland
buffers required by law and enabling more houses to be built.
Violation of County Wetland Protection Regulations: The public record indicates that the county has received
multiple complaints for several years regarding this activity. Until recently, these complaints have resulted in
investigations that were closed with no violations found, despite eyewitness testimonials, photographs and direct
on-site inspection. During this time many tons of fill have been dumped into the federally protected wetlands, and
new roads and drainage ditches have been built in the sensitive areas around them, in clear violation of the law.
Imagery of this activity is available on Google Earth and in satellite imagery contained in King County’s own data
bases. Until recently the county has done nothing to prevent this activity which also contributes to increased flood
risks in near-by properties as surrounding hydrology is affected.
1 In this regard, please see the attachment which assesses issues related to public process and transparency.
Enforcement of County Wetland Protection Regulations: Sustainable Redmond would appreciate an explanation
from the County for why multiple inspections of the site during the past five years have found no evidence of
wrongdoing. However, when the last formal complaint was received by your office several months ago, copying
state and federal officials, suddenly a set of violations were discovered, as if they had happened the day before
(please refer to ENFR14-0512).
Redress Requested: To remedy this situation, we are calling on the County to ensure that the wetland habitat and
surrounding hydrology are fully restored to their original state, and that all of the roads that were illegally built in
the wetland habitat and its legal buffer are removed.
HABITAT AND TREE PRESERVATION
Habitat Protection: Wetlands are a vital and dwindling habitat in King County, especially in the areas that have been
most affected by urban sprawl. Sustainable Redmond believes that the Evans Creek Natural Area is worthy of
stronger protection than the county has provided to date. The wetland provides important habitat to endangered
species of Chinook salmon as well as other protected species including Red Tail Hawks, Great Blue Herons, Bald
Eagles, Coho Salmon, Kokanee Salmon and Vaux’s Swifts. In addition, rare birds such as the American Bittern have
been sighted using the wetland for nesting purposes. The filling and building activities have impacted wildlife and
disrupted the hydrology of the wetland complex. The quality of the wetland habitat could be further compromised
by a centralized septic system proposed for the project that would be located near the wetland buffer.
Upland Tree Preservation and Landslide Risk: Based on the development plans provided to the local community by
the developer, at least 10 acres of mature Douglas fir forest on the slopes of Union Hill will be cleared to make room
for new houses. Sustainable Redmond is very concerned about the loss of trees on this scale, particularly as these
forests provide important upland habitat to species that use the Evans Creek Natural Area. Further, these trees are
located in a County-mapped “landslide hazard area” and landslide risk would be increased by the removal of the
soil retention qualities of this tree cover.
INTENSIFICATION OF USE
Community Character and Cultural Impact: In addition to the environmental impact of this development,
Sustainable Redmond would like the County to consider the broader impact of the project on the historic area and
the community that lives there. The developer intends to use a method known as “clustering” to develop homes
on one-acre lots, even though the area is zoned as RA-5. This practice is inappropriate in this particular location, as
it does not meet any of the criteria established by the County Comprehensive Plan, and is entirely unaligned with
the character of the Red Brick Road neighborhood. Building a gated community of 25 homes on 25 acres of allegedly
developable land, including roads, sidewalks, street lights and septic fields, would irreversibly destroy the
historically rural and agricultural character of the road and the valley. This is not sustainable development in any
sense of the word.
Traffic: Last year, the King County Landmarks Commission issued Certificate of Appropriateness #1318, authorizing
the developers to use the Red Brick Road as primary access, approving an additional 2,162 daily trips on the historic
road. This is a road designed over a century ago, whose condition is already significantly degraded. The Red Brick
Road is too narrow (18’) and lacks proper shoulders to meet even the most basic safe design standards. (Any
development along the Red Brick Road will require an exception to KCC 14.42.040, which requires developers to
improve impacted roads to county design standards.) Because the road cannot be modified, the balance between
safety and history must be accomplished by making every effort possible to limit traffic on the road. Developing
the subject property at the zoned RA-5 level will reduce the projected increase in traffic volume by 80% since five
homes could be built, rather than the 25 planned for in the proposed development.
In conclusion, Sustainable Redmond would like to ensure that any development that occurs in this area is
environmentally and socially sustainable. To that end, we ask the County to assure the following:
1) All illegal activity on the Gunshy Manor site must be fully remediated. The degraded wetland areas and
their buffers must be restored to their original state.
2) All new development must be performed within the legal guidelines established by the County for all of its
citizens, with a transparent public process that includes all interested parties. This includes requiring a full
SEPA assessment, as well as effective enforcement by County regulators of the full critical area buffers
prescribed by law - including wetland and landslide hazard areas.
3) All new development must respect the established zoning. The County should reject any new proposals
involving clustered development along the Red Brick Road.
4) The Certificate of Appropriateness #1318 issued by the King County Landmarks Commission should be
revoked. All new development in this area must be reviewed to ensure that it does not add significant traffic
to the already over-used Red Brick Road.
Thank you for your attention, and please feel free to contact Sustainable Redmond if there is anything we can do
to assist in finding alternative solutions that will benefit all parties involved in this matter. We would like to become
parties of record in this proceeding.
Robert Berg, Co-Chair Thomas Hinman, Secretary
Sustainable Redmond Sustainable Redmond
Attachment: Assessment of Public Process and Transparency Regarding Gunshy Manor
Copy by email to:
Rhonda Berry Chief of Operations, Office of the County Executive
Jeff McMorris Chief of Staff, Office of Councilmember Kathy Lambert
John F. Starbard Director, Permitting and Environmental Review, King County
Christie True Director, Department of Natural Resources & Parks (DNRP)
Bob Burns Assistant Director, DNRP
Julie Koler Historic Preservation Officer, DNRP
Randy Sandin Line Manager, Department of Permitting & Environmental Review (DPER)
Sheryl Lux Line Manager, Code Enforcement, DPER
Molly Johnson Managing Engineer, DPER
Jeri Breazeal Code Enforcement Officer, DPER
Michael Szerlog Manager, Aquatic Resources, U.S. EPA Region 10
Chan Pongkhamsing CWA Section 404 Enforcement Coordinator, U.S. EPA Region 10
Jonathan Smith North King County Regulatory Program Manager, US Army Corps of Engineers
Maia Bellon Director, Washington State Department of Ecology
Erik Stockdale Manager, Shorelands & Environmental Assistance, Washington Department of Ecology
Phil Anderson Director, Washington State Department of Fish & Wildlife
Stewart Reinbold Assistant Regional Habitat Program Manager, Washington Department of Fish & Wildlife